The Creative Economy Strategy was launched last month and went out for public consultation. While acknowledging the work done on surveying and researching the sector and providing legal recognition for it, we strongly feel the CES fails on many levels.

Firstly, we strongly disagree that this is a strategy at all. It does not include time-frames, budgets, and crucial details. It is more practical to call it a policy. Since in 2011, Malta had already launched its first National Cultural Policy, what is the present initiative attempting to achieve? The Creative Economy is a relevant subject in contemporary international policies. In fact, most of the positives in the new proposal being submitted are already mentioned in the existing Cultural Policy.

These include ideas such as removing the organisation of the National Festivals from the present Malta Council for Culture and the Arts and placing culture-related entities under the same Ministry. The National Cultural Policy already indicates what the different entities should be covering, and how they should be collaborating. This looks like a re-writing of the Cultural Policy, for the sole purpose of introducing a hitherto undeclared and/or hidden agenda. The government had already decided, through the Cultural Policy of 2011, where the cultural priorities for Malta lie. Starting the whole process again by re-writing a policy under the guise of a Creative Economy Strategy does not make sense.

At its worst, it dooms us Maltese to remain in a perpetual state of devising policies. While we understand that change is needed, especially in governance, the Cultural Policy launched in 2011 is supposed to be in operation and functioning. So why present a 'strategy' changing policy directions after only one year that it has been agreed upon by the government, and cultural operators after a consultation process with the general public? What is the agenda behind the CES?

The new reiteration of the CES seems presumptuous. It claims that its aim is to identify and address the barriers that are currently hindering growth for cultural and creative practitioners in Malta. It tries to do much more than that. It is trying to set an agenda for the whole cultural sector.

The CES is putting forward several agendas ranging from defining specific agendas for MCAST and the University of Malta, to proposals on how to create a National Theatre at the Manoel Theatre and how the Public Broadcasting Services should select programmes.

Why do entities such as the Univeristy of Malta, MCAST, the Manoel Theatre, PBS, Heritage Malta have to have a systems of management and tasks imposed on them? Hasn't the National Cultural Policy already defined their roles? Shouldn't these organisations collaborate and create their strategies implementing the Policy? The people in these organisations are experts in education, theatre, dance, music, heritage, cultural management and so forth. Even if the people authoring the CES were experts in all these sectors, it would be rather unhealthy to set an agenda for all stakeholders instead of leaving space for collaboration after strengthening governance.

The CES is suggesting we do away with a number of organisations such as the National Book Council. Diametrically opposed to this, our National Cultural Policy speaks of collaboration and of these organisations sharing projects and spaces. Now, a year later, why are we are proposing to remove them?

We feel that the ethos and priorities of the CES are dangerous and not in line with the National Cultural Policy. Creative industries are defined in the CES as industries (business) which have their origin in individual creativity. Publicly funded Culture includes cultural and artistic initiatives which are financed or subsidised by public funds.

Observers and specialists in the field, such as James Heartfield and Sara Selwood, specifically wrote on the differences between publicly funded culture and the creative industries. This CES clearly prioritises the latter. The CES speaks of market-led intiatives securing quality, and of 'an industry lens' to validate the cultural sector. We believe this is a very dangerous approach. Does being a professional artist mean you are or need to be financially profitable? One cannot base quality on the size of a bank account. Malta has seen highly financially successful artistic initiatives whose quality levels are debatable. Likewise, many of Malta's top artistic endeavours do generate profit and need government support.

Reading the CES, it is ironic to recall what one of the foremost politicians of the past century, John F Kennedy, had stated: "If art is to nourish the roots of our culture, society must set the artist free to follow his vision wherever it takes him." By making the artist subject to market forces, will an artist be set free? How do we let artists be artists? By making them financially independent? By promoting an entrepreneurship status as their reason d'etre? Or do we need to support artists, and in return, artists contribute to society? Does an artist need tax rebates or direct funding and commissions? We are not saying that there is a right way to argue this. Culture and the arts have always been a source of debate and it is fine for people to embrace a mentality, a way of working, an opinion. But it is very dangerous if the government prioritises creative industries over publicly funded culture.

Hypothetically, does the government expect the justice system to be a sustainable industry? Does the government expect the health system to be a sustainable industry? Just like these rights, access to culture is a human right. It has been stated by various ministers that when the government votes funding for the cultural sector, it is not subsidising but investing in culture. Why risk favouring an elitist cultural identity, and prioritising creative industries over publicly funded culture, thus delivering accessibility to profitable industries rather than to artists? The CES speaks of facilitating and creating a successful route to market for artists and arts organisations, in view of registering profits or becoming financially indepenedent.

Building financial resilience, where possible, for Malta's Arts and Cultural sector should be on our agenda, but not our priority. It is fine to minimise public spend by offering a route to market and export for financially successful artistic initiatives but not to impose it, or prefer it, as a natural successful course. Should a local band club adopt this route, it would ruin its identity. Not all the arts cater for the market. Moreover, if artists had to cater for market forces, they might make some sales, but this does not make them artists.

One can argue that the arts can tell the market what it needs and not vice-versa. A case in point is the local cliché that Maltese theatre does not sell. When artists led the market, Maltese plays sold out at the Manoel Theatre. Not all the arts can be self-sustained. For example, projects such as the Malta Music Memory Project (M3P), and the Staġun tat-Teatru Malti need regular government support and should be a government priority. Will these projects never be given priority because they need public funding? What happens to these projects? And what about our band clubs? Our carnival organisations? Creative industries are part of our cultural sector but not its be-all-and-end-all.

The CES tries to make a case for having one entity regulating both publicly funded culture and the creative industries. Opportunities for the industries should exist; opportunities for access to the market place and internationalisation should also exist, but these should not supersede publicly funded cultural projects: they should not be regarded as the natural success route for all artists and arts organisations. So why should we opt for a structure that treats an architecture project and a dance company, a contemporary visual artist and an employee of an advertising agency in the same way? The CES does not make a strong case for having this portfolio led by one entity. Malta Enterprise, the national development agency responsible for promoting and facilitating investment, has in the past dealt with schemes for the creative industries. Why doesn't Malta Enterprise collaborate more with entities such as the Arts Council instead of having one entity dealing with publicly funded culture and the creative industries? Why doesn't Malta Enterprise provide specific incentives to the industries as it has done in the past? Why create new roles instead of facilitating this collaboration?

Another issue we would like to raise is regarding what is the point of public consultation if most of these initiatives have already started being implemented? Cases in point: four out of seven investments in the route to market strategic outcomes have already been launched in previous budgets, credited to the authors of the CES; four out five incentives related to the internationalisation strategic outcomes have already been implemented; all three investments related to the education strategic outcomes have already been launched - to mention a few instances. It looks like this strategy has started, and at some point, someone realised, the public and the relevant entities needed to know about it.

Why has this working group deciding on budget measures concern itself with cultural issues? Was this within their remit? Isn't it too late, now, for public consultation? It would be interesting to discuss the outcomes to date, such as how many artists applied for the creative industry incentives including tax rebates, culture cards and so forth. Who is administering these new funds? Government ministries? Doesn't this clash with the National Cultural Policy that insists on the importance of the Arms Length Principle?

There are also some very serious and specific matters that need to be revised. Festivals Malta, whose remit includes the organisation of the national festivals, is listed in the legislation as having an executive Chair - a politically appointed board with an executive chairperson answerable to no board. This means that a minister can choose a board and an individual to direct this entity without issuing public calls. This is clearly and definitely not good-practice and not on the lines of the Cultural Policy (http://www.creativemalta.gov.mt/document-repository/legislation/view?searchterm=executive).

We believe the CES is trying to deal with too many issues and consequently the discussion on each subject seems vague and lacks clarity. It is also, at times, confusing. For example, while referring to the same entity, there is a continuous alternation between an entity called Malta Kreattiva and an entity called The Remodelled Malta Council for Culture and the Arts (with a revised legal Act). The document as a whole needs thorough proof reading before it is discussed further. It would have been best had this been done before it was presented for public consultation. We believe that, generally speaking, vagueness in the articulation of a strategy is dangerous; it is far more so when dealing with legal matters.

It is of public interest to ask how much did the government spend on this strategy, and who took the decision to invest in it? What if this money were invested in the organisations to aid in the implementation of the Cultural Policy as it has been agreed upon, involving all interested organisations and facilitating collaboration between them and other professionals? We believe this would have made much more sense.

A couple of years ago, more than 100 artists signed a petition to re-build the Royal Opera House as a national theatre. It is crucial that even policy and strategy are treated with the same urgency. We believe this strategy has a lot of issues and a lot of these questions need to be answered. We feel the government should focus on its priority and stick to the Cultural Policy it had launched only a year ago and collaborate with the stakeholders to devise collaborative, real, detailed strategies, implementing these policies.

Re-inventing the wheel leads to indulging in paper shuffling, expensive repetitions, energy wasting and needless speculation about what ulterior motives and hidden agendas fester in a Pandora's Box.